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<br />`vlU S. The Division suggests that the permit, revision to the permit indluding this TR, <br />and Board imposed monitoring requirements represem two levelk of monitoring <br />and sampling. 1: Routine monitoring as required in the permit as modified by <br />the TR. 2: Verification sampling to be conducted by a third patty. <br />The Division understandr that in order to protect the integrity of wells and <br />sampling stations, the company will collect all samples required under routine <br />monitoring. The Division further understands that third patty verification <br />sampling will be overseen by a third party, and that samples mpy be collected <br />either by BMRI or by the third party, whatever BMRI proposed. <br />The Division proposed that third party verification sampling b4 conducted no <br />more than 6 times in the first quarter of the year following apprdval of tJ~is TR, <br />no more than 3 times in the second quarter of that year, and ryo more than ,3 <br />times in the second half of that year. BMRI shall be notified 2 dkys prior to the <br />date of sampling. <br />RESPONSE: BMR has responded to this comment in a separate letter addressing third party <br />sampling, dated August 5, 1992. <br />6. The Division is not satisfied with the response. The reason for nt4nitoring major <br />t ~ cations and anions is to detect changes in water composition. that may 6e related <br />to mining. Measuring one without the other is a of very lintitedl use, as one is <br />more or less matched with the other to check the charge balance. If there is a <br />net negative (or positive) balance, then, in all likelihood, there tls an analytical <br />problem, and the labs need to be told about it. <br />RESPONSE: The major cations and anions aze being analyzed in the bi-weekly sampling and <br />also on asemi-annual basis from all of the surface water and grognd water sites. <br />It was only during the quarterly sampling periods that the major cations were not <br />analyzed. BMR agrees that the major cations and anions will continue to be <br />monitored on a bi-weekly and semi-annual basis and will add the major cations <br />to the quarterly water quality parameter list for analysis. <br />7. (No response required.) <br />8. (No response required.) <br />9. [No response required.) <br />10. [No response required.) <br />-3- <br />